EFTA01356929.pdf

Looking forward to speaking later today. Early afternoon cg 2pm CET would work best. Here a couple of thoughts - need refinement and challenge... Problem statement: Find client cases where we rely on some prior decision and do not question a 'borderline' client relationship - example Epstein where clearance was given again and again despite negative media and other alerts always referring back to Packard/Caruso onboarding decision (even though both had long since left DB). Potential solutions: 1) Assuming that negative media hits and respective clearances are stored: conduct a fuzzy logic search through all clearance statements looking for phrases such as "as per prior approval", " based on decision by", "...". Any hits to be reviewed by DCO/BI/AFC. 2) Search the KYC files for unusually senior sign off parties for onboarding in AFC and the business - come up with a way to electronically search for key words, such as " exception referral", "regional AFC Head", maybe a list of names like prior AFC Heads, Business Heads, COOs. Speak later, Wolfram Wolfram Lange Managing Director I Divisional Control Officer Deutsche Bank Wealth Management The Zig Zag Building, SW IE 6SQ, London, United Kingdom CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0043135 CONFIDENTIAL SONY GM_00189319 EFTA01356929